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    <title>2024 (5) TMI 282 - CESTAT AHMEDABAD</title>
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    <description>A customs demand for differential duty based on alleged non-fulfilment of preferential origin conditions was held time-barred because the relevant facts were already within departmental knowledge when the bill of entry was filed, the show cause notice was issued beyond the normal period, and no suppression, misdeclaration, or mala fide conduct justified extended limitation. Preferential exemption also could not be denied on assumptions or intelligence inputs alone, because the certificate of origin issued by the competent foreign authority required case-specific retroactive verification where origin was in doubt. In the absence of such verification, the denial of benefit was unsustainable, and the demand, penalty, and denial of exemption were set aside.</description>
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      <description>A customs demand for differential duty based on alleged non-fulfilment of preferential origin conditions was held time-barred because the relevant facts were already within departmental knowledge when the bill of entry was filed, the show cause notice was issued beyond the normal period, and no suppression, misdeclaration, or mala fide conduct justified extended limitation. Preferential exemption also could not be denied on assumptions or intelligence inputs alone, because the certificate of origin issued by the competent foreign authority required case-specific retroactive verification where origin was in doubt. In the absence of such verification, the denial of benefit was unsustainable, and the demand, penalty, and denial of exemption were set aside.</description>
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